OPINION.
MURDOCK, Judge:
The Commissioner mailed a notice to the petitioner that he had determined a deficiency of $88,286.78 in income tax and interest for 1948 against Egan, Inc., and that the deficiency, plus interest, "will be assessed against you * * * constituting your liability as transferees of assets of said Egan, Inc." The petitioner filed the present petition, the Commissioner filed an answer, and the petitioner filed a reply. The matter...
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